Comments
Regarding
the
Possible
Requirements
of
the
Phase
III
Cooling
Water
Intake
Structure
Regulations
Bayou
Steel
Corporation
is
a
member
of
the
Steel
Manufacturers
Association,
which
is
comprised
of
39
mini­
mill
companies
that
operate
125
steel
plants
throughout
North
America.
A
mini­
mill
takes
scrap
metal
and
utilizes
electric­
arc
furnaces
to
melt
the
scrap
into
steel,
making
mini­
mills
the
largest
recyclers
in
the
nation.

In
order
to
determine
how
many
mini­
mills
would
be
affected
by
the
possible
316(
b)
phase
III
rule
making
a
statement
and
question
were
sent
to
the
SMA
member
companies:

EPA
is
proposing
regulations
for
cooling
water
intakes
similar
to
the
316(
b)
phase
II
that
affects
existing
power
producing
facilities.

The
proposed
regulations
would
impact
those
facilities
that
use
cooling
water,
ie.,
have
a
cooling
water
intake
structure
withdrawing
water
from
U.
S.
waters
and
at
least
25%
of
the
water
is
used
for
contact
or
non­
contact
cooling;
they
have
an
NPDES
permit
(
or
are
required
to
obtain
one);
and
they
have
a
design
intake
flow
of
50
MGD
or
greater.

How
many
member
companies
will
this
affect,
ie.,
how
many
use
cooling
water
with
a
design
intake
of
50
MGD
or
greater?

Responses
were
received
from
30
facilities,
representing
17
companies
and
4,
including
Bayou
Steel
Corporation,
would
be
affected
by
the
316(
b)
regulations.

General
Comments
1)
While
there
may
be
many
facilities
whose
design
intake
flow
may
be
50
MGD
or
greater,
the
regulation
should
apply
to
those
who
actually
utilize
50
MGD
or
greater.
The
facility
should
be
able
to
demonstrate,
over
a
certain
period
of
time,
that
the
50
MGD
is
not
exceeded.

2)
Financially
­
Bayou
Steel
Corporation,
and
many
of
the
other
mini­
mills
in
the
country,
have
been
struggling
over
the
past
few
years
just
to
remain
in
business.
Bayou
Steel
Corporation
has
just
emerged
from
bankruptcy
last
month
and
considers
itself
lucky
to
still
be
in
operation.
The
monitoring
and
permitting
costs
alone
are
significant
and
would
be
a
large
impact
on
extremely
small
budgets.
Many,
if
not
all,
capital
and
other
projects
for
improvement
at
Bayou
Steel
and
most
other
mini­
mills
have
been
abandoned
or
postponed
indefinitely
due
to
limited
resources.

Wendy
Stehling
Bayou
Steel
Corporation
LaPlace,
LA
on
the
Mississippi
River
wendys@
bayousteel.
com
985/
652­
0322
